For years, the Alien Tort Statute has been hailed as the preeminent vehicle for incorporating, developing, and expanding norms of international law in the United States. Scholars...saluted the way that the Alien Tort Statute enabled the U.S. to demonstrate its commitment to upholding and enforcing international law norms. But what is striking about the Supreme Court’s pending decision in Kiobel v. Royal Dutch Petroleum, however, is how it has forced defenders of the ATS to rely on domestic law rather than international law to flesh out and resolve key legal questions arising in ATS cases. This has transformed the ATS into just another domestic law tort mechanism...[T]he Kiobel litigation has thus confirmed that the ATS is not a free-floating universalist tool for enforcing international law norms on behalf of the international community. It is a law of the United States, which authorizes courts to apply domestic American law to activities with some substantial connection to the United States...This new, more modest ATS is perhaps less interesting and attractive to international law scholars and advocates. But it is far more likely to survive as a meaningful tool for extraterritorial corporate regulation.